An Evaluation of the California Injury and Illness Prevention Program

An Evaluation of the California Injury and Illness Prevention Program

John Mendeloff
Wayne B. Gray
Amelia M. Haviland
Regan Main
Jing Xia
Copyright Date: 2012
Published by: RAND Corporation
Pages: 121
Stable URL: http://www.jstor.org/stable/10.7249/j.ctt3fh18d
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  • Book Info
    An Evaluation of the California Injury and Illness Prevention Program
    Book Description:

    The Injury and Illness Prevention Program (IIPP) requirement has been the most frequently cited standard in California workplace health and safety inspections almost every year since it became effective in July 1991. This evaluation of the IIPP measures program effectiveness using information on citations for violations of the program and data on worker safety in California.

    eISBN: 978-0-8330-7941-1
    Subjects: Management & Organizational Behavior, History, Law
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Table of Contents

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  1. Front Matter (pp. i-ii)
  2. PREFACE (pp. iii-iv)
  3. Table of Contents (pp. v-vi)
  4. FIGURES (pp. vii-viii)
  5. TABLES (pp. ix-x)
  6. SUMMARY (pp. xi-xviii)

    Occupational safety and health regulation tends to follow one of two paths: enforcement of compliance with hazard-specific standards, as in the United States, or requirements for procedures that more broadly address safety and health, as in most of the European Union. A frequent shortcoming of the U.S. approach, which is enforced by the Occupational Safety and Health Administration (OSHA), is failing to engage employers at a fundamental and comprehensive level. Top management commitment is essential for a strong safety effort, and involvement of frontline supervisors and other employees is also critical. Training workers to understand can also complement efforts to...

  7. ACKNOWLEDGMENTS (pp. xix-xx)
  8. ABBREVIATIONS (pp. xxi-xxi)
  9. 1. INTRODUCTION (pp. 1-6)

    The modern era in U.S. occupational safety and health regulation began more than 40 years ago, when the Occupational Safety and Health Act of 1970 became law and created the Occupational Safety and Health Administration (OSHA). Although OSHA sponsors consultation and education programs, it has relied primarily on enforcing a set of safety and health standards governing specific hazards through inspections and penalties. The act transferred most authority for workplace safety and health regulation from the states to the federal government; however, it allowed states to enforce the law as long as their programs were “as effective as” the federal...

  10. 2. CALIFORNIA’S INJURY AND ILLNESS PREVENTION PROGRAM (pp. 7-16)

    California’s occupational safety and health program has been in the political spotlight more than most OSHA programs. In January 1987, Governor George Deukmejian eliminated the Cal/OSHA program in order to reduce state spending.⁴ Federal OSHA then assumed the enforcement of federal occupational safety and health standards in the state. The federal role lasted only about a year because a referendum (Proposition 97) won voter approval in November 1988, overturning the governor’s action and restoring the state’s program.

    Shortly after the return of Cal/OSHA in 1989, the legislature passed Senate Bill (SB) 198, which required that every employer in California establish...

  11. 3. INJURY AND ILLNESS PREVENTION PROGRAM IMPLEMENTATION AND TRENDS IN COMPLIANCE (pp. 17-34)

    We begin our review of the IIPP’s implementation by looking at the frequency with which different provisions of the IIPP have been cited. After reviewing the characteristics of the inspections in which citations occur, we examine what has happened to compliance over time. Because evidence about noncompliance is available only for inspected workplaces and because inspections are not conducted randomly, we cannot draw firm conclusions about noncompliance in the universe of firms in the state. The inspection data do, however, provide some useful insights.

    Table 3.1 shows that §3203(a) accounts for about two-thirds of all violations of the IIPP. It...

  12. 4. LIMITATIONS OF PREVIOUS RESEARCH (pp. 35-38)

    Overall, the research base on the effects of safety programs is thin, especially for mandatory programs. Safety magazines are replete with articles with titles like “How We Reduced Our Injuries by 80 Percent,” but the representativeness of these reports is suspect because successes are much more likely to be written up and published than failures.

    A “regression to the mean” bias also often plagues these studies. This bias refers to the fact that new safety initiatives are often adopted as a response to an unusually bad year for injuries. Because the number of injuries at a workplace has a substantial...

  13. 5. EVALUATION DESIGN: THE CHALLENGE OF ESTABLISHING CAUSALITY (pp. 39-52)

    Many factors, in addition to the presence of a given safety and health program, affect the number of injuries that occur. Other major influences on reported injury rates include the following:

    financial incentives to report injuries and to prevent them—both are influenced by the features of the WC program and by other factors

    shifts in the percentage of inexperienced workers—reflecting economic and demographic trends

    changes in technologies

    management practices—lots of overtime, more pressure on production, labor–management relations.

    Even if all these factors remained unchanged from one year to the next, we would still not expect the...

  14. 6. STATE-LEVEL IMPACT (pp. 53-56)

    We stated earlier that nonfatal injury rates are too heavily influenced by changes in WC program changes to be a valid indicator of changes in risk. Nonetheless, we present in this chapter the rates for the total recordable rates for California and the United States for 1985 to 2001 from the BLS SOII. It shows an increase in the California rate in 1990 with almost no change in 1991 and 1992, the first years the IIPP was introduced. The California rate declines sharply after 1992, more sharply than the national rate, but a substantial share of that is probably due...

  15. 7. INJURY PERFORMANCE OF COMPLIANT AND NONCOMPLIANT FIRMS: THE LOOKBACK MODELS (pp. 57-62)

    In this chapter, we look at whether firms that had high injury rates within their industry were more likely to be noncompliant with the IIPP standard. Ideally, we would like to know whether noncompliance with the IIPP contributes to higher injury rates. Necessary, but not sufficient, conditions for that causal role are (1) that noncompliance and the injury rate are positively related and (2) that the noncompliance status precedes or occurs simultaneously with the injury rate. In the model we test here, we examine the relation between measures of injury performance and the status of IIPP compliance.

    In all cases,...

  16. 8. EFFECTS OF INJURY AND ILLNESS PREVENTION PROGRAM VIOLATIONS ON CHANGES IN INJURIES: THE CHANGE MODELS (pp. 63-66)

    The other issue we examined was whether citations for an IIPP violation were followed by reductions in injury rates. As explained earlier, prior studies have usually found that OSHA inspections that levied penalties were followed by reductions in injuries (Gray and Scholz, 1993; Gray and Mendeloff, 2005; Haviland et al., forthcoming). All those studies were carried out in the manufacturing sector in states where federal OSHA was responsible for enforcement. None of them had included AIs in the inspections they studied. In those states, AIs made up only 2 percent of all inspections, compared with 20 to 25 percent in...

  17. 9. CONCLUSIONS: THE IMPACT OF THE CALIFORNIA INJURY AND ILLNESS PREVENTION PROGRAM STANDARD (pp. 67-74)

    As we asked earlier, “Isn’t it obvious that carrying out the activities required by the California IIPP will lead to improvements in safety?” We think that the vast majority of safety professionals would answer “Yes.” It is certainly very plausible that they are correct. However, there is little evidence from the strongest types of evaluation to support that conclusion. Studies that randomly assign treatments, such as hazard surveys, worker training, and AI, to create treatment and control groups are extremely rare.

    Establishing that the elements of a safety and health program are indeed effective is an important task, especially if...

  18. APPENDIX A. CONSTRUCTION OF THE DATA SETS (pp. 75-76)
  19. APPENDIX B. MODIFICATIONS TO THE WORKERS’ COMPENSATION INFORMATION SYSTEM AND OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION DATA INITIATIVE DATA (pp. 77-78)
  20. APPENDIX C. LOOKBACK ANALYSES (pp. 79-90)
  21. APPENDIX D. REGRESSION RESULTS FROM CHANGE MODELS (pp. 91-96)
  22. REFERENCES (pp. 97-100)

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